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Sears v. Commissioner

Sears v. Commissioner is one of three cases decided in January 1991 in which premiums paid to wholly owned insurance companies were deemed deductible expenses.

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Substantial unrelated business, among other tests, was critical. [96 T.C. 61 (1991, aff'd in part, rev'd in part, 972 F.2d 858 (7th Cir. 1992).]

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